Tagged: compliance program requirements

Sapin II and French Anti-Corruption Enforcement

As more countries enter into the anti-corruption enforcement world, companies face exponential risks of detection and enforcement. Recently, Deputy Attorney General Rosenstein has commented on the need to avoid unfair enforcement actions by multiple jurisdiction based on a single course of conduct.  This approach has been reflected in FCPA enforcement actions involving multiple countries and resulting in division of fines and penalties. The United States...